Who’s responsible?

This isn’t so much about information as it is about governance.

“Regulators, Accounting Firms Spar Over Rule,” Wall Street Journal, September 22, 2014 C1. At issue is having the name of the engagement partner of a company’s accounting firm sign off on each public company audit.  And their name will be disclosed to investors.  The fight is over whether the disclosure is in a 10-K, and thus reasonably accessible to investors, or on a Form 2, which is harder to get.

A major failing of many information governance initiatives is the failure to designate one C-suite resident as the owner of the information governance program, with responsibility for what gets done and what doesn’t.  See also the Federal Sentencing Guidelines Manual.  A contributing cause to the failure of many information governance programs is the absence of a procedure by which the managers of each group of employees sign off at least annually on the compliance by those who report to the managers.

If your boss has to sign off that you’re in compliance, will he or she do more to find out how you’re doing?  Will you? What will happen to the culture, both in your group and in your company?

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Filed under Board, Compliance, Compliance, Compliance, Controls, Culture, Culture, Governance, Internal controls, Management, Oversight, Protect

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